A. Business Description Arbion targets the ultra-high net worth market and was formed to provide an alternative to the traditional wealth management and private banking model by providing a full wealth and investment management service to private individuals, their families and institutional clients. Arbion creates and manages global investment strategies with the goal of generating the best outcome for its clients, with expertise in multi- asset and fixed income investing and hedge fund portfolios. We are an SEC-registered investment adviser and are also authorised and regulated by the Financial Conduct Authority (FCA) in the United Kingdom to provide investment management and investment advice. We have been operating since 1st March 2010 when we received FCA authorisation in the United Kingdom. Arbion Limited is a private limited company incorporated in England & Wales under company number 07044573 with it's registered office at One Connaught Place, London, W2 2ET. The ownership structure consists of the following: 100% is owned by Arbion Holdings Limited – a private limited company incorporated in the United Kingdom. Arbion Holdings Limited is owned by the Arbion management team with no person directly or indirectly having the right to vote 25 percent or more of the companies shares. The companies directors who have fiduciary responsibility are Carnegie Smyth, Kirin Ohbi, Daniel Pasini and Marco Pabst. B. Types of Services offered Arbion provides discretionary management and non-discretionary management services to HNW clients, Corporates and Trusts. Clients can access these services via the below product or service solutions: - Segregated Investment Management Portfolio - Model Portfolio Service (MPS) – Not available for US investors - IFSL Arbion Fund range (UCITS collective investment scheme) – Not available for US investors Arbion has an in-depth understanding of each client’s personal requirements, whilst utilising the strength of our investment process to deliver real risk-adjusted returns. The key drivers which shape our investment philosophy are as follows:
• We manage global multi asset portfolios;
• We focus on strategic asset allocation as the primary source of investment returns;
• We use tactical asset allocation with caution;
• We implement portfolios efficiently via a blend of direct investments, best-in-class funds and derivatives. We take a conservative view on currency risk and hedge foreign exchange risk where appropriate to reduce portfolio volatility. We are benchmark aware but have a strong focus on preserving capital in times of market stress. We aim to produce returns over a time horizon appropriate and relevant to the investment strategy we are managing. We believe in the benefits of asset class and geographical diversification, and employ strict risk control parameters. We have designed investment strategies that seek to deliver returns that are commensurate with the level of risk taken in Global Fixed Income, Conservative Multi-Asset, Balanced Multi-Asset, Growth Multi-Asset, Global Equity and Hedge Fund only portfolios. We also construct tailored profiles dependent on specific client circumstances and objectives. We are not affiliated with any provider, custodian or asset manager and as such are only incentivised to employ products which are most suitable for our clients. Our portfolio construction is grounded in making decisions solely on the basis of generating the appropriate returns for our clients. We use multiple routes to market and control portfolio costs resulting in efficient portfolio management.

We employ the use of direct sovereign bonds, exchange traded funds, third party fund managers, derivatives and structured products to ensure that we use appropriate instruments for any strategy that we seek to implement. Between them our team of professionals have over 180 years’ experience in the industry. As a result, we have developed extensive access to leading industry research expertise through our counterparties. As of the 30 October 2020, Arbion launched 3 UK Collective Investment Schemes. Arbion is the Investment Manager of the Funds, IFSL Fund Services are the ACD. These funds are not permitted to be marketed outside of the UK and will not be registered under the United States Securities Act of 1933, as amended. They may not be offered or sold in the United States of America, its territories and possessions any State of the United States of America and the District of Columbia or offered or sold to US Persons. The ACD has not been and will not be registered under the United States Investment Advisers Act of 1940. C. Do we tailor our services to the individual needs of clients? Prior to initial investment Arbion will conduct a detailed consultation with the client in order to assess their risk appetite; based on this consultation a suitable risk profile will be determined and this profile may include defined limits with regard to maximum and minimum allocations to asset classes and currencies; it is at this stage that any client specified restrictions will also be taken into account. As part of the initial assessment (or subsequent assessments) clients may impose reasonable restrictions on Arbion’s discretionary authority with respect to investments in specific sectors (e.g. funds investing in tobacco companies) or assets (e.g. fixed income, derivatives, etc). Client restrictions must be in writing and form part of the client’s investment management agreement. We tailor our investment management services to the needs of individual clients. We are a UK based wealth manager and as such primarily look after clients resident in the United Kingdom (or may have moved to the US) as well as clients resident in other jurisdictions, and as such portfolios are tailored to an individual’s specific investment requirements and tax status. D. Wrap fee programs Arbion does not participate in wrap fee programs. E. Discretionary client assets and non-discretionary client assets Arbion does not hold any client assets. Rather a client will open an account with a bank that will provide custody, execution and settlement services to the client. The client is required to sign the banks services agreement separately. Arbion will undertake the investment management of the client’s assets using the bank custody, execution and settlement services. The client remains the owner of the assets at all times with assets held on a fully segregated basis and is an account holder with the bank like any other. The client grants Arbion a “limited power of attorney” on the account that enables Arbion to undertake investment management activities on behalf of the client but not remove assets from the account. This can only be done by the client. All brokerage transactions e.g. buying and selling equities, fixed income for the client, are executed and settled by the bank with which the client holds the account. At the commencement of a relationship with Arbion a client will choose which bank they wish to open an account with. Amount of Managed Assets As of 31/12/2023, we were actively managing $1,8bn clients' assets on a discretionary basis and $295m on a non-discretionary basis.